This Policy sets out how SPAG identifies, discloses, assesses, records and manages conflicts of interest — actual, potential and perceived. Its purpose is to protect the independence, impartiality and objectivity of SPAG's decisions, research, advisory work, partnerships and use of resources.
It does not prohibit anyone connected with SPAG from holding legitimate professional, financial, family, civic, academic, political or organisational interests. Those interests are expected. What the Policy requires is that they are declared and managed wherever they could affect — or could reasonably be seen to affect — the proper exercise of an SPAG responsibility.
The primary obligation is disclosure, not abstinence. A disclosed conflict implies no wrongdoing and does not disqualify anyone from all SPAG activity; most are managed with a note on the file or a step back from one decision. Concealing one is the breach.
French law establishes no single general offence of conflict of interest for private associations. But a conflict can create or reveal exposure to corruption, misuse of association resources, fraud or breach of contractual and professional duties — which is why SPAG addresses a conflict before it turns into conduct.
Actual
A private, professional, financial, family, political or organisational interest that is presently capable of interfering with the impartial, independent or objective exercise of an SPAG responsibility.
Clause 4.1Potential
An interest not currently in conflict, but which could reasonably become so through a foreseeable decision, assignment, relationship or change of circumstances. It is disclosed before it matures, not after.
Clause 4.2Perceived
Where a reasonable and informed outsider could conclude that an interest may improperly influence judgement — whether or not the person believes any actual influence exists. Believing yourself impartial does not settle the question.
Clause 4.3Governance and the Bureau
A conflicted Bureau member never determines how their own conflict is handled; the non-conflicted members do. A conflicted President may not use the powers of the office to control the matter, and a conflicted Secretary-General or Treasurer may not control records, payments or procedural steps affecting the outcome.
Clause 10.1–10.3Recruitment and procurement
Any relationship with a candidate, bidder, supplier, consultant, grantee or donor must be declared. A conflicted person takes no part in drafting criteria, shortlisting, scoring, interviewing, negotiating, recommending, approving, certifying performance or authorising payment.
Clause 11.1–11.2Research and publications
Researchers, advisers, authors and reviewers declare interests capable of affecting the independence of SPAG analysis. No funder, client or partner may suppress findings, dictate conclusions or require a misleading presentation of evidence. Nobody with a material stake holds sole or decisive control over a review or publication decision.
Clause 12.1–12.5Gifts, hospitality and travel
Nothing may be solicited or accepted that could reasonably be understood to influence a decision or reward improper conduct. Cash and cash equivalents are never accepted. Offers made during a live procurement, recruitment, grant or investigation are normally declined. Modest, infrequent, transparent hospitality with a genuine professional purpose may be accepted.
Clause 13.1–13.4Outside roles and public office
External work is permitted, and must be declared where it overlaps materially with an SPAG responsibility, creates competing duties, involves an entity affected by an SPAG decision, or could confuse whose interests a person represents. SPAG title, branding, contact lists and confidential information are never used to advance an undisclosed external interest.
Clause 14.2, 14.5Close relationships
Ordinary family and personal relationships are not prohibited. But nobody determines the appointment, remuneration, evaluation, contractual terms, disciplinary outcome or financial benefit of a close relative, partner, household member or anyone with whom their impartiality is materially affected.
Clause 15.2–15.3Disclose
Promptly on becoming aware and, wherever practicable, before taking part. The disclosure covers the nature of the interest and how it relates to the SPAG matter — not irrelevant private detail.
Clause 6.1–6.2Assess
By someone not themselves conflicted, weighing the interest, the role, the significance of the decision, access to confidential information, the degree of discretion, reputational risk, and whether a reasonable observer would question impartiality.
Clause 8.1Manage
A proportionate measure, specifying what it covers, how long it lasts, who implements it and when it is reviewed. Most disclosures need nothing more than a record.
Clause 8.2–8.3Record
Entered in the conflict-of-interest register with only what is necessary: the person, the interest, the affected matter, the date, the assessment, the measure and who decided. Access is limited to legitimate need.
Clause 16.1–16.3Update
A disclosure is refreshed when the interest materially changes, and the authority is told when a conflict ends so a management measure can be lifted. Office-holders also declare at least annually.
Clause 6.5, 7.1Out of the discussion, not just the vote
A recused person takes no part in the substantive discussion, recommendation, evaluation, negotiation, vote or approval — except to supply factual information the non-conflicted decision-maker asks for.
Out of the room
Where practicable the person leaves the meeting, or the relevant part of it, while deliberation and decision take place. In remote meetings, access to the discussion and the materials is restricted where necessary.
Recorded in the minutes
The record states that a conflict was declared and that the person did not participate, without unnecessary personal detail. A recused person is not counted as having participated.
No control through the back door
A conflict is not adequately managed if the person keeps practical control of a matter they are formally recused from — by choosing their substitute, directing staff, or drafting the decision that others then approve.
Disclosing costs you nothing
Where there is uncertainty, disclose. Anyone who discloses a possible conflict in good faith is not treated adversely merely because the interest turns out to be immaterial.
"Everyone already knows" is not disclosure
A conflict is not disclosed because it is generally known, was mentioned socially, appears on a public website or could be found in public records. Formal disclosure through the proper process remains the individual's responsibility.
No self-approval of money
Nobody approves their own claims, invoices or reimbursements, save under a documented emergency procedure followed by independent review. Ordinary reimbursement requires another competent person.
Related-party transactions are justified and approved
No purchase, consultancy, grant or other transaction may be structured to confer an undisclosed benefit. A related-party transaction must be demonstrably in SPAG's interests, documented, and approved by a non-conflicted authority that has weighed necessity, value and alternatives.
Familiarity is not automatic exclusion
Knowing a candidate or supplier does not by itself disqualify anyone. What matters is the closeness of the relationship, the discretion involved, and whether independent safeguards can preserve fairness.
Your politics stay private
Disclosure covers formal roles, mandates, candidacies and offices that materially intersect with SPAG work. It does not extend to private political opinion or lawful voting choices, and no such information is collected to administer this Policy.
No retaliation for stepping back
Nobody may be penalised for making a good-faith disclosure, declining to take part in a conflicted matter, seeking advice under this Policy, or reporting suspected misconduct through an authorised channel.
A late-discovered conflict is assessed, not assumed fatal
Where a conflict comes to light after a decision, the competent authority considers whether the process or outcome was materially affected and whether reconsideration or another remedy is needed. A conflict found after the fact does not automatically invalidate the decision.
Suspect a conflict is being concealed?
Deliberate concealment of a material conflict, improper influence, manipulation of a decision, or retaliation connected with a disclosure can be reported under the Whistleblowing & Complaints Policy. A concern is not treated as false or malicious merely because it is unsubstantiated or because the person raising it was mistaken in good faith.
